CSTA

Fire Safety in Purpose-Built Blocks of Flats

National Guidance

CSTA

Colin Todd – Director

Malcolm Hoare - Senior Consultant

www.cstodd.co.uk

office@cstodd.co.uk

01252 792088

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• Impact of Fire Safety Order

• Limited guidance available

• Inconsistent enforcement

• Unsuitable fire risk assessments.

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• Existing purpose-built flats

• Not a design guide

• Includes the flats as well as

common parts.

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Guidance will be applicable to flats if conversion was carried out in accordance with the then current Building Regulations

Compartmentation will need to support a ‘stay put’ strategy

If not, ‘LACoRS Guide’ will be more appropriate.

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• Includes sheltered housing and cluster flats

• Covers flats above commercial premises

• Does not cover HMOs

• Does not cover commercial parts or

separate ancillary facilities.

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• Includes owner-occupied, social housing and private rented flats

• Term residents covers all occupants

• Life safety not property protection

• Not operational fire-fighting

• Applicable to England only.

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• General principles only

• Not prescriptive

• Provides benchmarks not rules

• Allows for alternative approaches.

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Those who manage and give advice on standards in purpose-built blocks of flats including:

Private rented sector landlords

Social housing providers

Residents’ management companies

‘Right to manage’ companies

Managing agents or facility managers

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• Enforcement officers in local

housing authorities

• Enforcement officers in fire and rescue

authorities

• Consultants and contractors carrying out fire risk assessments.

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• DCLG Sleeping Accommodation

Guide

• LACoRS Guide

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• Building Regulations

Approved Document B

• British Standard 5588 Part 1

• British Standard 9991:2011

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Part A: Fires in Flats

Part B: Fire safety in flats

Part C: Fire safety law

Part D: Fire risk assessment

Part E: Managing fire risk – Preventing fires

Part F: Managing fire risk – Fire protection

Part G: Managing fire risk – Management

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Appendix 1: History of Design Standards

Appendix 2: Steps in a FRA

Appendix 3: Selecting a competent fire risk

assessor

Appendix 4: Fire Safety Advice for Residents

Appendix 5: Examples of Fire Action Notices

Appendix 6: FD & A Systems

Appendix 7-13: Case Studies

Glossary

Biography

Index

Part A: Safe as Houses?

Fire in flats and their impact

Relative Risk

0

5

10

15

20

25

Proportion of People

Living in Flats

Proportion of

Domestic Fire Deaths

in Flats

Proportion of

Dwelling Fires in Flats

10

23

25

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High rise = high risk? No greater likelihood of a fatality in a high- rise block than low-rise block Bungalow more likely to result in a fatality than in high-rise block Risk? The risk is in the dwelling not the building Stay Put policy? In 2009/10, over 8,000 fires in blocks of flats – only 22 fires required evacuation of 5 or more people by Fire and Rescue Service.

Part B: Fire Safety –

How blocks of flats differ from other residences

DESIGN PRINCIPLES

PURPOSE BUILT FLATS

AND SHELTERED

ACCOMMODATION

Flat

Flat

Flat

Flat

stairs

Flat Flat Flat

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• No requirement for simultaneous evacuation of

purpose-built blocks

• ‘Stay put policy’ is different from other buildings

• Residents in flat of origin evacuate and call the Fire

Service - all other residents safe to remain in their

flats

• Fire and Rescue Service attendance is a factor?

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• Evacuation of disabled residents

• Who is responsible?

• ‘Stay Put’ policy

• Personal Emergency Evacuation Plans?

• Information for Fire and Rescue Service?

Part C: The law governing fire safety

in blocks of flats

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Legislation applicable to existing flats:

• Regulatory Reform (Fire Safety) Order

2005

• Housing Act 2004

• Building Regulations 2010 (Material

Alteration)

Need to consider material alterations within flats

Classic contraventions are internal doors and flat

entrance doors

Powers to require rectification exist for only 12

months

Regularisation possible.

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• Applies to common parts only up

to and including flat entrance doors

• Plant rooms, store rooms etc

• Flats are classed as domestic

premises and are outside the scope

of the Order.

• The Employer

• Person having control of premises includes a person

who, by virtue of a contract or tenancy, has an

obligation of any extent in relation to

• Maintenance or repair of premises

• Maintenance or repair of anything in or on the

premises

• The safety of the premises.

• Freeholder

• Social and Private Landlords

• Residential Management Company

• Right to Manage Company

• Managing Agent

• If workplace, the Employer

• A Wide Range of People with duties

under the Order

• Definition Depends on Contracts

• Managing Agent may be RP or may be

Other Person

• Contractors - Fire Risk Assessors

• Any person who is, or may be, lawfully

on the premises

• Any person in the immediate vicinity of

the premises and who is at risk from a

fire on the premises

• Residents – Visitors – Contractors

• Not fire-fighters on operational duties

• The Responsible Person must make a

suitable and sufficient assessment of

the risks to which relevant persons are

exposed for the purpose of identifying

the general fire precautions needed to

comply with the Order.

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• Measures to reduce risk of fire and fire spread

• Means of escape

• Measures for securing that means of escape can be safely and effectively used

• Means for fighting fires

• Means for detecting and giving warning

• Action to be taken in event of fire – training - instruction – procedures.

Must record prescribed information if:

• 5 or more employed - Licence applies –

Alterations Notice is in force

Prescribed Information includes:

• Significant findings – measures taken –

measures that will be taken (Action Plan) –

Any group of relevant persons especially at

risk (disabled/vulnerable).

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• Housing Health and Safety Rating

System

• One of the 29 hazards covered by the

HHSRS is fire

• The system is risk based and uses a

formula to generate a numerical score which

determines the action taken.

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• HHSRS is applied to individual dwellings and the common escape routes used by the residents of that dwelling

• Overlap in legislation between the Housing Act and the Fire Safety Order

• Potential for overlap in enforcement

• Useful for enforcement of measures within flats (internal doors, ventilation ducts).

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• The Fire Safety Order generally

enforced by fire and rescue

authorities

• The Housing Act (HHSRS)

enforced by local authorities

• Enforcement Protocol.

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Fire Safety Order :

Notice of Deficiencies – Action Plan

Enforcement Notice – Prohibition Notice

Alterations Notice.

The Housing Act:

Improvement Notice – Prohibition Order

Emergency remedial action.

Building Regulations:

Rectify unauthorised material alterations

Regularisation of unauthorised work.

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• Legal implications:

• The freehold company may have limited

rights of entry and no powers to enforce

in leasehold flats

• In many cases the flat entrance doors will

belong to the leaseholder

• May have to consider action against

individual leaseholders.

Part D:

Fire Risk Assessment

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• FRA carried out at design stage

• FRA is carried out as snagging exercise

• FRA needs to be carried out by

consultants

• FRA needs to identify all latent defects.

Identify Fire

Hazards

Identify People

at Risk

Evaluate

Remove

Reduce Protect

from Risk

Record Plan

Inform Instruct

Train

Review

PAS 79

(Nine

Steps)

Relevant

Information Identify

hazards &

controls

Assess

likelihood of

Fire

Determine fire

protection

measures

Assess

management

Likely

consequences of

fire

Assess fire

risk

Formulate

action plan

Review

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• Type 1 – Common parts only

(non-destructive) survey to

satisfy FSO

• Type 2 – Common parts only

(destructive) survey if there are

concerns over structural

deficiencies and fire spread

beyond flat of origin into common

areas.

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• Type 3 – Common parts and

flats (non-destructive) survey

that goes beyond scope of FSO

• Type 4 – Common parts and

flats (destructive) survey that

goes beyond scope of FSO if

there are concerns over fire

spread.

• Discussed in ACOP under management regulations

• Competence means having sufficient training and

experience or knowledge and other qualities

• A competent person in employer’s employment is

preferred

• Employer involvement is necessary

• Nomination of others does not absolve employer of

responsibility

• External services will be advisory only

(cont.)

• Competence does not necessarily depend on

particular skills or qualifications

• Simple situations may require only:

- An understanding of relevant current best

practice

- An awareness of the limitations of own

experience and knowledge

- Willingness and ability to supplement experience

/knowledge, when necessary, by external advice

NEW COMPETENCY

CRITERIA FOR FIRE RISK

ASSESSORS

THIRD PARTY

CERTIFICATION

BAFE SCHEME SP205

UKAS ACCREDITATION

Part E:

Managing Fire Risk - Preventing Fires

Fire Hazards

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Smoking: Policy

Controls

Signs

Arson: Secure Boundaries

Access Control

Security CCTV

External Housekeeping

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Electrics:

• Good Practices – IET Regulations

• Competent Contractors

• Inspection and Testing fixed installations

Gas:

• Gas Safe Regulations

• Inspection and Testing

Meters and services in stairways

• Generally not a significant risk.

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Heating and Ventilation Systems:

• Regular maintenance and servicing

• Fuel cut off devices

Lightning:

• BS EN 62305 provides advice

• If fitted regular inspection and testing

Contractors:

• Control of works on site

• Policy – permits to work etc.

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Storage in common areas:

• Refuse

• Recycling

• Prams, bikes

Storage in plant, boiler rooms and

service riser cupboards.

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Two alternatives

discussed:

• Zero tolerance

• Managed use

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• Simple to adopt

• No ambiguity

• Easier to police

• Not risk proportionate

• Penalises those who could

manage common parts

• Denies chance to improve living

environment.

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• Makes block ‘homely’

• Benefits elderly and disabled people

• Removes need for communal stores

• Can be risk specific

• More difficult to adopt

• Scope for misunderstanding

• More difficult to ‘police’.

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Bicycles, Prams etc:

• Good management – security

• Should not pose an obstruction

Mobility Scooters:

• Risk assess in common areas

• Need good management – security

• No charging in common areas.

Part F: Managing Fire Risk - Protection

Fire Safety Measures

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• Not reasonable or risk proportionate to apply

current standards

• Need to consider and review original

design against current benchmark (History)

• Risk assess the need to seek

improvements for the safety of residents.

Do building fire

precautions meet current

standards?

Adequate fire protection

Do fire precautions meet

standards at time of

construction?

Identify shortcomings in

relation to current

standards

Do departures from current

standards create significant

risk?

(Fire Risk Assessment)

Upgrade fire precautions

Prioritize requirements

Identify shortcomings from

that standard

Have these been relaxed?

Are there still

shortcomings from current

standards?

YES

YES

Rectify shortcomings

YES

YES

NO

NO

NO

NO

NO

YES

Assessment of Existing Buildings

Adequate compartmentation is a basic

requirement in all blocks of flats.

Fire separation between flats – between flats and

the common parts – between common parts and

ancillary accommodation.

Standards have changed over the years – the

standard prior to the 1960’s will be different to that

of today.

In new purpose-built flats the following should be constructed as

compartment floors and walls:

Every floor between storeys

Every wall separating a flat from any other part of a building

Every wall separating a refuse storage chamber

60 minutes fire resistance (small converted 30 min)

Blocks of flats over 30m in height - automatic sprinkler system in

the flats.

In principle the risk increase with the height,

size and number of flats in a block:

In 2 to 5 storey blocks – with a limited number of

flats - it might be possible to accept 30 minutes

fire resistance within the overall risk assessment.

6 Storey and above – should be 60 minutes.

Where adequate fire separation can not be met or

readily achieved by upgrading, compensatory

measures may need to be considered:

Improving existing MOE

Improving fire protection to escape routes

Provision of AFD

Provision of sprinklers.

• The potential for fire spread in both the common

parts and within flats should be considered.

• Ventilation ducts, service risers, refuse chutes

and flues.

• Fire Dampers - Shunt Ducts

• Fire stopping around services, pipes and cables

where they pass through walls and floors.

• Enclosure of shafts or risers in fire resisting

structure with fire doors.

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Means of Escape

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Considered in two parts:

• From flat of origin into common escape

route

• Using common escape route to a place

of safety.

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Escape from flat of origin (not part of Fire

Safety Order):

Safety of residents in their own flats

Internal flat layout – means of escape

Provision of smoke/heat alarms.

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Common escape routes:

Safety of residents outside their own

flats

Use of common stairs/balconies

Fire protection of escape routes.

OPTIONS:

Flats with a floor not more than 4.5m above

ground – similar to a house

Flats with a floor more than 4.5m above ground:

• Limited travel distance

• Protected hall

• Alternative exit/s.

• Most flat designs

incorporate limited travel

distance or alternative

exits

• Protected halls and

lobbies with self-closing

doors within the flats are

seen as an obstacle to

older residents.

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Common Issues:

• Removal of fire resisting walls

• Fire doors removed or changed

• Self-closing devices removed/disabled

• Bedrooms become inner rooms

• Alternative exits removed or blocked

• Alternative exit via shared balcony

• Excess travel distance

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Means of Escape in the Common Parts

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Two options available:

• Protected corridors or lobbies leading to a protected stairway and limit travel distance

• Provide independent alternative escape routes.

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• Corridor or lobby is a protected route with

fire resisting walls and doors (includes

flat entrance door)

• Stairway is enclosed in fire resisting

construction

• Smoke control to protect stairway

• Restrict surface finishes in escape

routes.

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• Small purpose built blocks

• Top floor not more than 11m above

ground – no more than 3 storeys above

ground storey.

• Protected lobby or corridor - limit

travel distance (4.5m or 7.5m)

• If only 2 flats per floor - internal hall in flats provides protection to stairway.

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• External Stairways

• Escape over flat roofs

• Basement stairs

• Stairs serving enclosed car parks, boiler

rooms.

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• Security locks on all exits should be

easily openable without the use of a

key

• Security gates and grilles

• Electronic security locks to final exits

must fail safe and may require an

override control

• Schemes vary in size,

complexity and facilities

provided

• Some may have on-site staff,

many don’t

• Extra care schemes

• Limitations of residents should

be taken into account

MEANS OF ESCAPE

• Provide protected corridors or

lobbies leading to a stairway

• Limit travel distance from flat

entrance door to a stairway,

lobby or corridor door

• Most residents should be

capable of escape without

outside assistance.

TRAVEL DISTANCE

• An elderly or disabled resident should not have

to travel far in a corridor to reach a place of

safety

• 7.5 metre travel distance from each dwelling

entrance door to a fire door giving access to:

- A protected stairway

- A protected lobby

- A door subdividing a corridor.

TRAVEL DISTANCE

• Cross-corridor doors provide smoke control by limiting

the length of the corridors

• Corridors should be provided with some form of smoke

ventilation

• Travel distance in communal areas and community

rooms should be relevant to risk

• If provided, escape lifts should comply with

BS 9999.

PROTECTED CORRIDORS

• Ancillary accommodation such as communal lounges

and kitchens should be separated with 30 minutes fire

resistance

• Cupboards containing electric distribution equipment

and meters, cleaners and store rooms should be

separated with 30 minutes fire resistance

• Boiler rooms and other high risk rooms should be 60

minutes fire resistance

DISABLED EVACUATION

• Evacuation of disabled residents

• ‘Stay put’ policy

• Personal emergency evacuation

plans

• Information box.

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• Smoke control design has changed over

the years

• Current guidance is based on smoke

containment to protect the common

stairways – smoke dispersal was used

in earlier design guides

• Natural or mechanical ventilation of

lobbies or corridors is required where they

adjoin stairways

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• Natural smoke ventilation in lobby/corridor can be:

• Permanently open (PV) - Manually openable (OV) - Automatic opening (AOV)

• Current guidance - for single stairway is AOV – multiple stairways is OV’s

• Mechanical ventilation includes pressurisation systems.

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• Protected stairways also require some

means to ventilate smoke that may enter

the stairway.

• Minimum 1metre square vent at head of

stairway.

• In multiple stairways this can be OV – in

single stairway it should be AOV.

Blocks that

Do Not Meet Current

Design Benchmarks

Blocks with increased travel distance

Flats that open direct onto stairways

Blocks with unsatisfactory smoke control

Fire resisting doors that do not meet current standards.

CSTA

Options based on risk assessment:

Accept original (notional) fire door

Upgrade the door (upgraded) strips and seals

Replace with FD30S door and frame.

CSTA

Single Direction Escape:

Unventilated lobby/corridor

• 4.5m – 6m accepted

• Increases to 7.5m – upgraded doors

• Beyond 7.5 should be ventilated

Ventilated lobby/corridor

• 7.5m to 10m accepted

• 10m to 15m upgraded doors, PV or AOV

• Beyond 15m FD30S doors, AOV

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Escape in two directions lobby or corridor:

• Increase from 30m to 40m accepted

• TD in excess of 40m – replacement FD30S

doors, AOV or detection - specialist advice.

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Up to 4 storeys:

• Notional 30 minute doors, OV or windows

5 to 6 storeys:

• Upgraded 30 minute doors, OV windows,

internal hall with FR doors to kitchen/lounge

Over 6 storeys:

• FD30S doors, AOV, Internal protected hall,

detection.

CSTA

• Single stair: flats opening directly on to stairs

Up to 6 storeys OV, over 6 storeys AOV/PV.

• Single stair: lobby/corridor; up to 6 storeys OV,

over 6 storeys AOV or PV in lobby/corridor

• Flats designed on smoke dispersal: consider cross corridor doors and OV or PV in corridor.

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Options based on risk assessment:

Accept original (notional) fire door.

Upgrade the door (upgraded) strips and seals.

Replace with FD30S door and frame.

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• Doors must be good fit in frame – 3/4mm gaps

• In good condition no openings (cables, locks)

• Fitted with self-closing device – rising butt hinges

should be changed.

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Other issues:

• Glazing – in and over

the door

• Letterbox

• Spy hole

• Cat flap.

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Single stair with doors from flats opening

directly onto stairs:

• 4 storeys – Notional 30 minute doors

• 5/6 storeys – Upgraded 30 minute

doors

• Over 6 storeys – FD30S doors and

frames.

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Multiple stairways, lobby/corridor:

• Satisfactory TD, notional 30 minute doors

should be acceptable

• Increased TD or unsatisfactory smoke

control upgraded 30 minute doors or

replacement FD30S and frames.

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External balcony or deck access single stairway (dead

ends):

• Notional door FD 20 (SC still required)

• Any glazing over 1.1m not required to be FR,

FR letterbox not essential

External balcony or deck access multiple stairways or

alternative MOE:

• Flat entrance doors not required to be FR.

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Current standard:

• Ideally entered direct from open air, 60

minute FR, not in protected stairways or

lobbies

Existing blocks:

• Refuse/ bin rooms in stairway or corridor

enclose in FR and provide PV

• Refuse chute in stairway or corridor,

enclose in FR, provide shutter in bin room

and/or sprinklers in bin room.

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• Generally no requirement for ‘FIRE EXIT’

signs in single staircase blocks

• ‘FIRE EXIT’ signs required to indicate

alternative routes

• Signs on doors

• General fire safety notices.

EMERGENCY ESCAPE

LIGHTING

• Not required in two storey blocks with good

borrowed lighting

• Generally required in the common parts, stairs and

corridors of other blocks

• Plant rooms and service rooms

• Required in common areas, stairs, corridors and

communal rooms in sheltered accommodation.

FIRE DETECTION AND

ALARM SYSTEMS

British Standard

Fire detection and alarm

systems for buildings

Part 1.

BS 5839: Part 1:2012

BSi

British Standard

Fire detection and alarm

systems for buildings

Part 6.

BS 5839: Part 6:2004

BSi

BS 5839 -1

Most commercial

premises and

workplaces

BS 5839 - 6

Small sleeping risk

premises, HMO’s &

domestic premises

BS 5839 -1

M – manual call points &

sounders

L1 – All areas covered

L2 – Escape routes, risk rooms &

specific areas

L3 – Escape routes, risk rooms

L4 – Escape routes only

L5 – Specific areas

P1 – Property protection

P2 – Property protection

BS 5839 -6

LD1

A – Same as BS 5839-1

LD2 LD3

B – Rarely used

C – Linked to intruder alarm D – Mains + battery smoke alarm

E – Mains smoke alarm F – Battery smoke alarm

FIRE DETECTION AND ALARM

• No requirement for a common fire

detection and alarm system in general

needs purpose-built blocks

• Against the principles of ‘stay put’

• May be required for automatic vents.

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• Individual flats should be provided with a

minimum of a Grade D LD3 system with

smoke alarms in the circulation spaces in

accordance with BS5839-6.

• There may be a need to upgrade to an

LD1 or LD2 system with additional smoke

and heat alarms in individual flats as

compensation or higher risk groups.

• All alarms should be linked

A) ALERT RESIDENTS TO FIRE IN THEIR OWN FLAT

B) ALERT F&RS (BUT MINIMIZE FALSE ALARMS)

C) EARLY WARNING OF A FIRE IN COMMUNAL

FACILITIES

SHELTERED ACCOMMODATION

• If no common facilities, no requirement for a

common alarm

• If there are common facilities, L4 or L5 system to

cover common areas linked to a call centre

• No sounders in flats, not designed for

simultaneous evacuation

• Early call facility to Fire &Rescue Service.

SHELTERED ACCOMMODATION

Common alarm should only

sound in:

• Common escape routes

• Warden accommodation

• Communal areas or ancillary

accommodation

It should not sound in flats – stay put

SHELTERED ACCOMMODATION

Individual smoke and heat alarms within each

flat should be linked

Smoke alarm in hall, lounge, and smoke alarm

or sounder in bedroom

Heat alarm in kitchen

Generally these would be linked to a social

alarm centre with call back facilities and

provision to pass call onto Fire and Rescue

Service.

CSTA

• Generally no requirement for

provision of fire extinguishers in

common parts

• Extinguishers required in plant and

service rooms

• Required in ancillary accommodation in

sheltered accommodation, such as kitchens

and laundry rooms.

CSTA

Dry and wet rising mains, fire fighting lifts.

No requirement to provide

or upgrade facilities in existing

blocks.

However, there is a requirement to maintain what is provided.

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• Person responsible to manage fire safety

• Access to competent advice

• Inspections/visits by staff

• Communication with residents

• Fire safety arrangements

• Testing and maintenance.

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Engaging with residents:

• Fire prevention (inc security)

• Action in the event of fire

• What ‘stay put’ means

• Policy on common parts

• Pitfalls of alterations

• How to test smoke alarms

• Use of Residents’ Handbooks.